SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) responding to a draft interpretive guidance on prevailing market prices and mark-ups for transactions in municipal securities issued by the MSRB, MSRB Notice 2010-10. SIFMA requests that the MSRB (1) allow for a more flexible approach in determining prevailing market price; (2) permit a more flexible approach to documenting transactions; (3) expand the exemption from the guidance to include all transactions by dealers with a SMMP; (4) expand the discussion of the situations in which a bond dealer may consider itself a market maker; and (5) provide dealers with more guidance regarding the definition of “contemporaneous cost”.